Dear Atlantic County Prosecutor's Office,

This is a request for public records made under OPRA and the common law right of access. I am not required to fill out an official form. Please acknowledge receipt of this message.

Records requested:

All records and data created and/or collected as part of the investigation of the
automobile vs. pedestrian crash that occurred at the intersection of Baltic and
Michigan Avenues in Atlantic City, NJ on 1/28/2023, under police accident report
number 23-9166, involving pedestrians Madison Drent and Lance Leski, and driver Mr.
MD Yousuf. This request includes, but is not limited to, the following records and
electronic data:

o All data downloaded from the subject car's ECM or black box module.
o All investigation materials, notes, reports, measurements, photographs, videos
(body/dash cam footage), witness statements, traffic camera/video footage, security
camera/video footage, crash reconstruction analyses and related data, summonses
issued, test results regarding drugs and alcohol, cell phone records, texts and data
obtained from or regarding the driver's phone, and all findings and conclusions
relating to the subject crash.
o Photographs and videotapes of all inspections of the subject car
o Records, data and findings related to the driver and vehicle involved in the crash.
o All statements -- whether written, videotaped or tape recorded -- given by Mr. Yousuf
and/or any witness
o All police accident reports, including preliminary reports, supplemental reports, and
final reports
o Photographs and videotapes of all inspections of the crash scene
o All records concerning the filing of any criminal charges against Mr. MD Yousuf,
including, for example, court docket sheet, indictment or similar document, criminal
complaint or similar document, search warrants, arrest warrants, bail documents,
grand jury determinations, hearing transcripts and the like.

Very truly yours,
Paul D. Brandes, Esq.
(215) 568-3500

Thank you for your reply. However, please note that I was advised via email yesterday from the OPRA representative for Atlantic City that "the black box data is currently in the possession of the County Prosecutor."

In light of that statement, please provide the black box/ECM module data per my OPRA request, which specifically sought, among other things: "All data downloaded from the subject car's ECM or black box module."

If your office no longer has the data, please advise on where it is located.

Thank you very much.

Very truly yours,

Paul D. Brandes